A series of secret tests on cattle feed conducted by
the federal government earlier this year found that more than half the
feed tested contained animal parts not listed on the ingredients, according
to internal documents obtained by The Vancouver Sun.

The test results raise troubling questions about whether
rules banning the feeding of cattle remains to other cattle -- the primary
way in which mad cow disease is spread -- are being routinely violated.

According to internal Canadian Food Inspection Agency
documents -- obtained by The Sun through the Access to Information Act
-- 70 feed samples labelled as vegetable-only were tested by the agency
between January and March of this year. Of those, 41 (59 per cent) were
found to contain "undeclared animal materials."

"The presence of animal protein materials [in vegetable
feeds] may indicate ... deliberate or accidental inclusion of animal proteins
in feeds where they are not supposed to be," said an internal memo
to the president of the Canadian Food Inspection Agency last April that
described the test results as "worrisome."

The memo, from Sergio Tolusso, feed program coordinator
for the CFIA, said the contamination could also have been caused inadvertently
-- for example, through the transporting of different feeds in the same
trucks.

Controlled experiments have shown an animal needs to
consume as little as one milligram of infected material -- about the size
of a grain of sand -- from an animal with bovine spongiform encephalopathy
(BSE) to develop the brain-wasting disease.

Michael Hansen, an expert on mad cow disease with the
U.S.-based Consumers Union, the independent research institute that publishes
Consumer Reports, said the CFIA tests are troubling.

"The fact that stuff that is labelled as vegetable
feed, that 59 per cent of it has animal material, that's incredibly high,"
said Hansen, who has a PhD in biology. "This should be a wake-up call
to CFIA. It doesn't look good."

Michael McBane, national co-ordinator for the Canadian
Health Coalition, a watchdog group, said the tests suggest the feed ban
is not being adequately enforced.

"It demonstrates the fact that the [feed] ban is
basically meaningless," McBane said. "It's pretty well recognized
that we have mad cow disease in Canada because of contaminated feed. It's
the frontlines in the battle to stop the spread."

Consumption of beef from cows infected with BSE has been
linked to the development in humans of variant Creutzfeldt-Jakob disease
(vCJD), a deadly brain-wasting illness.

In the 1990s, the United Kingdom suffered an outbreak
of BSE that was followed by more than 100 people dying of vCJD.

In 1997, as a precaution, Canada implemented a ban on
feeding ruminants -- like sheep and cattle -- to other ruminants. However,
ruminant remains can still be fed to chicken and pigs, and chicken and
pig remains can be fed to cattle.

With the discovery of a lone Alberta cow with BSE in
May 2003, the feed ban took on added importance.

"Compliance with the existing ban is a critical
factor in preventing the disease from spreading to other animals,"
Tolusso wrote in January in an internal memo to CFIA president Dick Fadden.
"Major non-compliance with the feed ban cannot be tolerated, and measures
to address the risks of domestic ruminants being exposed to prohibited
animal proteins must be initiated promptly."

According to the documents, concerns about the integrity
of Canada's feed were first raised in the summer of 2003, when U.S. authorities
turned back seven separate shipments of vegetable feed from Canada because
they were contaminated with animal parts.

"The animal proteins detected in these [shipments]
were not supposed to be in the feeds," Tolusso explained to Fadden
in an August 2003 memo. "While the results initially appear to be
very worrying, it is difficult to interpret the real significance of these
findings."

To determine if there was a wider problem with Canadian
feed, the CFIA initiated a nationwide testing program of both domestic
and imported feed in early 2004.

To make the job easier for its scientists, the agency
collected only samples that were labelled as vegetable-only, such as soy
meal or grain -- feed that shouldn't have any animal parts in it at all.

The samples were tested by CFIA scientists in Ottawa,
who looked at a few grams of each sample under a microscope.

The first batch of 70 samples found that a majority contained
animal protein.

And the worst results were for feed manufactured in Canada.

Of the 28 domestic feed samples tested by the agency,
20 had undeclared animal protein in them -- 71 per cent of all the samples.

In comparison, just under half of the imported samples
-- 19 of 39 -- contained animal parts.

(Three of the 70 samples were of undetermined origin.)

In an interview with The Sun, Tolusso said he couldn't
say how many of the contaminated feed samples contained cattle remains.

"In the absence of real identifiable material like
feathers and hairs, [scientists are] left looking at bone fragments and
pieces of muscle tissue, and those are virtually impossible to determine
what species they might come from," Tolusso said.

As a result, he said, the agency doesn't have a clear
idea of how much cattle remains have been fed to other cattle.

"We knew entering this testing survey that there
was a possibility we could generate more questions for ourselves than we
could answer," he said. "We hadn't done this before and to some
extent we weren't sure what we were going to find. And it does make it
worse that you can't explain what they actually are."

In addition to concerns over testing, the CFIA documents
obtained by The Sun also reveal problems with the feed mills that produce
animal feed.

There are about 550 commercial feed mills in Canada.

According to a memo to Fadden last March, an initial
inspection last year of several hundred of those mills found that 21 per
cent were not complying with federal regulations.

Most of those violations were minor and quickly corrected.

However, the report notes that seven mills had "major
non-compliance issues" involving things like proper labelling and
record-keeping.

And three mills were failing "to prevent the contamination
of ruminant feeds with non-ruminant feeds containing ruminant meat and
bone meal" -- the exact type of contamination that can spread BSE.

Two of those three mills successfully recalled their
contaminated product, but the report notes that in one case, some of the
feed was sent out and consumed by cattle.

Tolusso said the CFIA's feed tests led to some follow-up
inspections in feed mills, but no further recalls of feed.

Earlier this month, the CFIA announced it would ban the
parts of cattle most susceptible to BSE infection -- such as the spine
and brains -- from all feed, including that destined for pigs and chickens.

Such animal parts are known as specified risk materials
(SRMs).

Tolusso acknowledged the agency's tests were one reason
for the stricter regulations.

"If we recognize there are lots of opportunities
for the wrong kind of protein to get in the wrong kind of feed ... then
perhaps the more prudent thing to do is to remove some of these higher-risk
tissues altogether," he said.

Some experts have argued that Canada should go even further
and keep cattle remains out of feed altogether, as is done in Europe.

"What they need to do is cut out the loopholes [and]
stop feeding mammalian protein to food animals," Hansen said.

McBane agreed.

"At the end of the day, the only way to stop the
transmission of BSE is a complete stop on recycling animal protein,"
he said.

Tolusso said the CFIA believes a ban on just the riskiest
materials -- like cow brains -- will eliminate most of the risk of BSE
spreading in Canada.

But he said the agency hasn't ruled out a total ban on
cattle remains in feed.

"At this point, we've put our best guess forward
[on] the most appropriate approach," he said. "But that doesn't
preclude that ... we might have to go to a more strict ban."